ML20062C495

Responds to 780813 NRC Ltr Re Violations Noted in Inspec Repts 50-317/78-22 & 50-318/78-16.Corrective Actions: Rad-Chem Technicians Properly reinstructed;CCI-607B Rev by 781201;air Supply Maint Procedures Written by 781101

ML20062C495
Person / Time
Site:	Calvert Cliffs
Issue date:	11/08/1978
From:	Lundvall A BALTIMORE GAS & ELECTRIC CO.
To:	Crocker H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20062C494	List: IR 05000317/1978022 ML20062C488 ML20062C495 ML20062C500 ML20062C504
References
78108, NUDOCS 7811090030
Download: ML20062C495 (3)

Text

B ALTIMORE G AS AND ELECTRIC COMPANY P.O. BO X 14 7 s S A L.TI M O R E. M A R Y t. A N D 212o 3 Antwum C.LumovALL..la.

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som, U.S. Nuclear Regulatory Commission Docket No. 50-317 Region I 50-318 631 Park Avenue License No. DPR-53 King of Prussia, Pennsylvania 19h06 DPR-69 ATTENTION: Mr. Hilbert W. Crocker Gentlemen:

This refers to your Inspection Report 50-317/78-22 and 50-318/78-16 which transmitted items of apparent non-compliance with NRC requirements.

Enclosure (1) to this letter is a written statement in reply to the items noted in your letter of September 13, 1978.

Should you have further questions regarding this reply, we will be pleased to discuss them with you.

Very truly yours,,

i (A. E. Lundvall,

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Vice President - Supply AEL/LBR/nrc Enclosure (1) l 3r7 Q 318 Q

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ENCLOSURE (1)

I Reely to NRC Letter Dated Sectember 13. 1978 NRC Instection Resort 50-317/78-22; 50-318/78-16 ITIM A. RESPONSE The Radiation Safety and Chemistry Foreman held a training session on August ik, 1978, and re-instructed the Rad-Chem technicians in the use of procedure RCP 2 kO2, with special emphasis placed.on the use of rejection stickers and the prevention of use of instrumentation whose calibration due date has passed. In addition, to aid in avoiding future recurrence of this item, the Principal Technician responsible for instru-ment repair and calibration has been instructed to ensure that instruments which have been rejected are not accessible for use by personnel. Full compliance is considered to have been achieved as of August ik,1978.

ITEM 3. RESPONSE CCI-610A vas cited as providing "the means of the appropriate evaluation -

of the effectiveness of the on-the-job training program for the qualifi-cation of Radiation and Chemistry technicians pursuant to CCI-607B", and "vas not incorporated into the training program defined by CCI-607B anc subsequently was not utilized in the training of Radiation and Safety technicians". In Paragraph 3 of the Details portion of the Inspection Report, it further states that Section C.2 of CCI-610A requires a completed qualification card and check-off sheet. The report failed to include the :==Mng sentence in Section C.2 which states: ' Preparation by referencing a qualification card or_ check-off sheet is satisfactory documentation in "on-the-job training" section.'

It should ce noted that CCI-610A is a generic procedure thus covering general requirements for maintenance of "?ersonnel Training Records",

while CCI-6073 is a specifie procedure governing the criteria for

" Radiation Safety and Chemistry Personnel Training" and recortis. CCI-6073 is consistent with ANSI N18.1-1971, Section 5.3 in that a suiterale training program was established for technicians to properly prepare them for their assignments and to meet the requirements of the facility. Therefore ,

CCI-6073 is the procedure for providing the means for the appropriate evaluation of the effectiveness of the on-the-job training program for the qualification of Radiation Safety and Chemistry Technicians. In effect, CCI-6073 amplifies the requirements of CCI-610A for its specific training program. CCI-6073 requires documentation of on-the-job training by use of a " Radiation Safety and Chemistry Qualification Card" to demon-strate satisfactory performance and/or knowledge in the areas covered in on-the-job training. This is consistent with the requirements of Section C.2 of CCI-610A, which gives the option of using either a qualifi-~

cation card or a check-off sheet to document on-the-jcb training.

After revision of CCI-6073, previously accumuisted dccumenta-ion of technician training was inadvertently removed from the individual training

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Enclosure (1) heply to NRC Letter Dated September 13, 1978

Page 2 records. At the time of the referenced inspection this documentation was not available, but it has been subsequently recovered and refiled.

1 Documentation of compliance is available for appropriate evaluation of on-the-job training of all technicians who meet ANSI N18.1-1971 require- i ments; therefore, we have been in full ecmpliance in this instance.

On-the-job training of three technicians and one trainee who currently do not meet ANSI N1.8.1-1971 have been documented in accordance with '

l CCI-6073's qualification card which is consistent with Section C.2 of CCI-610A requirements. Therefore, it is considered that we have been in full compliance with Technical Specification 6.h, and this should not i be an item of non-compliance. We request that you review this item in

light of the above infomation.

However, to aid in preventing future misconceptions cencerning training requirements for Rad-Chem Technicians , CCI-6073 vill be revised to require a check-off sheet to further identify the en-the-job training in addition to the currently utilized qualification card. This revision vill be completed by December 1,1978.

ITEM C. RESPONSE Written procedures for the naintenance of a supply of respirable air, in ecmpressed gas cylinders, not previously purified, and for verifying i

the quality of this air, are being developed and will be implemented as part of our respiratory protection program by November 1,1978.

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